A Comparative Analysis of Digital Banking Cybersecurity Regulations in Indonesia and Selected ASEAN Countries

Abstract

Digital banking growth has increased the importance of cybersecurity regulation as banks become more dependent on electronic systems, data processing, cloud infrastructure, and third-party technology providers. This article examines how effective Indonesia’s current legal framework on digital banking cybersecurity is compared with selected ASEAN countries in ensuring cyber resilience, data protection, and institutional accountability, and why comparative analysis is necessary for improving Indonesia’s cybersecurity governance. Using comparative normative legal research, this study analyzes Indonesian regulations, including OJK regulations, Government Regulation No. 71 of 2019, and Law No. 27 of 2022, alongside regulatory approaches in Singapore, Malaysia, and the Philippines. The discussion shows that Indonesia has established an important legal foundation, but its framework remains fragmented and less operationally specific than selected ASEAN comparators. The article argues that Indonesia needs clearer cyber resilience standards, stronger integration between data protection and banking cybersecurity rules, better third-party risk governance, and more explicit board-level accountability to strengthen trust, legal certainty, and digital banking resilience.